Using Data to Break Barriers

With the upcoming release of a recruitment barriers analysis tool, the Equal Employment Opportunity Commission gives HR a new way to evaluate the employment life cycle for potential barriers.

Wednesday, September 20, 2017
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The Equal Employment Opportunity Commission is planning to release the recruitment part of its new root cause analysis tool this month to help agencies with their barrier analysis, according to Lori Grant, the Equal Employment Opportunity Commission's assistant director of the Agency Oversight Division.

The EEOC also plans to issue guidance on the other employment cycles "throughout the year" on the Federal Sector EEO Portal, FedSEP, and the EEOC's website, Grant said.

While the tool is being finalized, Grant recommended agencies evaluate the five employment stages -- recruitment, selection, career advancement, promotion and retention -- using the questions EEOC used to help build the root cause analysis tool.

Grant also made it clear that agencies "will not be required to use the tool" and "can choose to rely on EEOC guidance," so they should continue conducting the barrier analysis to identify and eradicate barriers to employment. For the analysis due on Jan. 31, 2018, the Office of Personnel Management and the EEOC jointly urged agencies to focus on barriers to Hispanic employment between the GS-12 and Senior Executive Service levels, although the tool can be used to delve into other types of barriers as well.

Coordinating between HR and EEO

To ensure the barrier analysis is effective, "EEO and HR should partner in evaluating the employment life cycle for potential barriers," especially since HR has concurrent diversity and inclusion obligations, Grant said.

"The HR office should provide the EEO office with access to all relevant data, including workforce demographics, applicant flow data, recruitment efforts, climate assessment results, exit interview results, grievance statistics" and others, she said.

After analyzing the data, "EEO and HR could collaborate on training and recruitment initiatives to address particular barriers" depending on the findings."

As a best practice, "the HR office should invite the EEO office to attend strategic planning meetings and other types of meetings that involve workforce changes," she said.

Identifying triggers

Although agencies may be tempted to select a single employment cycle, they should look at the "entire employment life cycle" to identify the most significant triggers -- or things that may exclude or disadvantage employees on the basis of gender, race, ethnicity, or disability -- within the workplace. This will help the agency prioritize its barrier analysis efforts, she explained.

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In addition, "the most common mistake agencies make involves the perception that the goal is to increase the participation rate of a particular EEO group." However, "barrier analysis should focus on removing policies, procedures, and practices that limit employment opportunities," not simply increasing the representation of a particular group, she said.

This means "rather than establishing an objective to increase hiring, agencies should identify a specific policy or practice that should be amended or abolished."

When analyzing potential barriers, Grant also recommended creating a list of all possible reasons for the trigger and evaluating each of those reasons, as well as interviewing hiring officials, program leaders, employees, affinity groups, union representatives and other individuals with knowledge of possible triggers.

"To achieve the best result," Grant said practitioners also should consider "using a diversity council so the agency can encourage collaboration within its offices and quickly learn about the underlying causes of the trigger."

Anjali Patel is cyberFEDS'® legal editor in Washington. Send questions or comments about this story to



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